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20 Ohio opinions name it 1 courts 2013–2026 11 in the last five years
The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
State v. Kelleygreen2 sentences2024See Tolle, at ¶ 14; State v. Leonhart, 4th Dist. Washington No. 13CA38, 2014-Ohio-5601, ¶ 36 ; State v. Eckler, 4th Dist. Adams No. 09CA878, 2009-Ohio-7064 , ¶ 48; Veney, supra, at ¶ 13 (“Before accepting a guilty or no-contest plea, the court must make the determinations and give the warnings required by Crim.R. 11(C)(2)(a) and (b) and notify the defendant of the constitutional rights listed in Crim.R. 11(C)(2)(c)”); State v. Kelley, 57 Ohio St.3d 127, 128 , 566 N.E.2d 658 (1991) (“When a trial court or appellate court is reviewing a plea submitted by a defendant, its focus should be on wheth 2024See Tolle, at ¶ 14; State v. Leonhart, 4th Dist. Washington No. 13CA38, 2014-Ohio-5601, ¶ 36 ; State v. Eckler, 4th Dist. Adams No. 09CA878, 2009-Ohio-7064 , ¶ 48; Veney, supra, at ¶ 13 (“Before accepting a guilty or no-contest plea, the court must make the determinations and give the warnings required by Crim.R. 11(C)(2)(a) and (b) and notify the defendant of the constitutional rights listed in Crim.R. 11(C)(2)(c)”); State v. Kelley, 57 Ohio St.3d 127, 128 , 566 N.E.2d 658 (1991) (“When a trial court or appellate court is reviewing a plea submitted by a defendant, its focus should be on wheth | 4 | 4 |
State v. Nerogreen2 sentences2022“While the court must strictly comply with the requirements listed in Crim.R. 11(C)(2)(c), the court need only substantially comply with the requirements listed in Crim.R. 11(C)(2)(a) and (b).” Id., citing Veney at ¶ 18. {¶13} In order to substantially comply with Crim.R. 11, “a slight deviation from the text of the rule is permissible; so long as the totality of the circumstances indicates that the defendant 9 subjectively understands the implications of his plea and the rights he is waiving[.]” (Internal quotations omitted.) State v. Callaghan, 9th Dist. Summit No. 29431, 2021-Ohio-1047, ¶ 7 2021When a trial judge fails to explain the constitutional rights set forth in Crim.R. 11(C)(2)(c), the guilty or no-contest plea is invalid ‘under a presumption that it was entered involuntarily and unknowingly.’ [State v.] Griggs, 103 Ohio St.3d 85 , 2004- Ohio-4415, 814 N.E.2d 51 , ¶ 12; see also [State v.] Nero, 56 Ohio St.3d at 107, 564 N.E.2d 474 , citing Boykin [v. Alabama], 395 U.S. [238,] 242-243, 89 S.Ct. 1709 , 23 L.Ed.2d 274 . | 3 | 5 |
State v. Smithgreen2 sentences2024See Tolle, at ¶ 14; State v. Leonhart, 4th Dist. Washington No. 13CA38, 2014-Ohio-5601, ¶ 36 ; State v. Eckler, 4th Dist. Adams No. 09CA878, 2009-Ohio-7064 , ¶ 48; Veney, supra, at ¶ 13 (“Before accepting a guilty or no-contest plea, the court must make the determinations and give the warnings required by Crim.R. 11(C)(2)(a) and (b) and notify the defendant of the constitutional rights listed in Crim.R. 11(C)(2)(c)”); State v. Kelley, 57 Ohio St.3d 127, 128 , 566 N.E.2d 658 (1991) (“When a trial court or appellate court is reviewing a plea submitted by a defendant, its focus should be on wheth 2024See Tolle, at ¶ 14; State v. Leonhart, 4th Dist. Washington No. 13CA38, 2014-Ohio-5601, ¶ 36 ; State v. Eckler, 4th Dist. Adams No. 09CA878, 2009-Ohio-7064 , ¶ 48; Veney, supra, at ¶ 13 (“Before accepting a guilty or no-contest plea, the court must make the determinations and give the warnings required by Crim.R. 11(C)(2)(a) and (b) and notify the defendant of the constitutional rights listed in Crim.R. 11(C)(2)(c)”); State v. Kelley, 57 Ohio St.3d 127, 128 , 566 N.E.2d 658 (1991) (“When a trial court or appellate court is reviewing a plea submitted by a defendant, its focus should be on wheth | 3 | 3 |
Boykin v. Alabamared2 sentences2021When a trial judge fails to explain the constitutional rights set forth in Crim.R. 11(C)(2)(c), the guilty or no-contest plea is invalid ‘under a presumption that it was entered involuntarily and unknowingly.’ [State v.] Griggs, 103 Ohio St.3d 85 , 2004- Ohio-4415, 814 N.E.2d 51 , ¶ 12; see also [State v.] Nero, 56 Ohio St.3d at 107, 564 N.E.2d 474 , citing Boykin [v. Alabama], 395 U.S. [238,] 242-243, 89 S.Ct. 1709 , 23 L.Ed.2d 274 . 2021When a trial judge fails to explain the constitutional rights set forth in Crim.R. 11(C)(2)(c), the guilty or no-contest plea is invalid ‘under a presumption that it was entered involuntarily and unknowingly.’ [State v.] Griggs, 103 Ohio St.3d 85 , 2004- Ohio-4415, 814 N.E.2d 51 , ¶ 12; see also [State v.] Nero, 56 Ohio St.3d at 107, 564 N.E.2d 474 , citing Boykin [v. Alabama], 395 U.S. [238,] 242-243, 89 S.Ct. 1709 , 23 L.Ed.2d 274 . | 2 | 2 |
State v. Blackmangreen1 sentence2026Traditionally, “a defendant is not entitled to have his plea vacated unless he demonstrates he was prejudiced by a failure of the trial court to comply with the provisions of Crim.R. 11(C).” State v. Blackman, 2023-Ohio-3535, ¶ 15 (6th Dist.), quoting Dangler at ¶ 16 . | 1 | 1 |
State v. Ballardgreen1 sentence2023See Tolle, at ¶ 14; State v. Leonhart, 4th Dist. Washington No. 13CA38, 2014-Ohio-5601, at ¶ 36 ; State v. Eckler, 4th Dist. Adams No. 09CA878, 2009-Ohio-7064 , at ¶ 48; Veney, supra, at ¶ 13 (“Before accepting a guilty or no-contest plea, the court must make the determinations and give the warnings required by Crim.R. 11(C)(2)(a) and (b) and notify the defendant of the constitutional rights listed in Crim.R. 11(C)(2)(c).”); State v. Kelley, 57 Ohio St.3d 127, 128 , 566 N.E.2d 658 (1991) (“When a trial court or appellate court is reviewing a plea submitted by a defendant, its focus should be o | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Bishop (Slip Opinion)
green
2 sentences2021“The court must make the determinations and give the warnings that Crim.R. 11(C)(2)(a) and (b) require and must notify the defendant of the -4- constitutional rights that Crim.R. 11(C)(2)(c) identifies.” State v. Bishop, 156 Ohio St.3d 156 , 2018-Ohio-5132 , 124 N.E.3d 766, ¶ 11 . {¶8} “While the court must strictly comply with the requirements listed in Crim.R. 11(C)(2)(c), the court need only substantially comply with the requirements listed in Crim.R. 11(C)(2)(a) and (b).” Bishop at ¶ 11 . 2021“The court must make the determinations and give the warnings that Crim.R. 11(C)(2)(a) and (b) require and must notify the defendant of the -4- constitutional rights that Crim.R. 11(C)(2)(c) identifies.” State v. Bishop, 156 Ohio St.3d 156 , 2018-Ohio-5132 , 124 N.E.3d 766, ¶ 11 . {¶8} “While the court must strictly comply with the requirements listed in Crim.R. 11(C)(2)(c), the court need only substantially comply with the requirements listed in Crim.R. 11(C)(2)(a) and (b).” Bishop at ¶ 11 . | 7 | 2019–2021 |
State v. Veney
green
2 sentences2022Analysis {¶5} In his first assignment of error, Harris argues that the trial court “fail[ed] to advise him at the time of his guilty plea that he was waving his constitutional right to confront the witnesses against him.” The state argues that the 3 OHIO FIRST DISTRICT COURT OF APPEALS court sufficiently advised Harris of this right when it asked him, “Do you understand that you do have the right to require the prosecutor to bring in witnesses to prove your guilt beyond a reasonable doubt?” The state contends that any ambiguity in that language can be “clarified by reference to * * * the plea 2022Analysis {¶5} In his first assignment of error, Harris argues that the trial court “fail[ed] to advise him at the time of his guilty plea that he was waving his constitutional right to confront the witnesses against him.” The state argues that the 3 OHIO FIRST DISTRICT COURT OF APPEALS court sufficiently advised Harris of this right when it asked him, “Do you understand that you do have the right to require the prosecutor to bring in witnesses to prove your guilt beyond a reasonable doubt?” The state contends that any ambiguity in that language can be “clarified by reference to * * * the plea | 5 | 2014–2023 |
State v. Leonhart
green
2 sentences2024See Tolle, at ¶ 14; State v. Leonhart, 4th Dist. Washington No. 13CA38, 2014-Ohio-5601, ¶ 36 ; State v. Eckler, 4th Dist. Adams No. 09CA878, 2009-Ohio-7064 , ¶ 48; Veney, supra, at ¶ 13 (“Before accepting a guilty or no-contest plea, the court must make the determinations and give the warnings required by Crim.R. 11(C)(2)(a) and (b) and notify the defendant of the constitutional rights listed in Crim.R. 11(C)(2)(c)”); State v. Kelley, 57 Ohio St.3d 127, 128 , 566 N.E.2d 658 (1991) (“When a trial court or appellate court is reviewing a plea submitted by a defendant, its focus should be on wheth 2024See Tolle, at ¶ 14; State v. Leonhart, 4th Dist. Washington No. 13CA38, 2014-Ohio-5601, ¶ 36 ; State v. Eckler, 4th Dist. Adams No. 09CA878, 2009-Ohio-7064 , ¶ 48; Veney, supra, at ¶ 13 (“Before accepting a guilty or no-contest plea, the court must make the determinations and give the warnings required by Crim.R. 11(C)(2)(a) and (b) and notify the defendant of the constitutional rights listed in Crim.R. 11(C)(2)(c)”); State v. Kelley, 57 Ohio St.3d 127, 128 , 566 N.E.2d 658 (1991) (“When a trial court or appellate court is reviewing a plea submitted by a defendant, its focus should be on wheth | 3 | 2023–2024 |
State v. Gowdy
green
2 sentences2026Specifically, a trial court must “‘must make the determinations and give the warnings required by Crim.R. 11(C)(2)(a) and (b)’” and “‘notify the defendant of his or her constitutional rights enumerated in Crim.R. 11(C)(2)(c).’” State v. Gowdy, 2025-Ohio-5575, ¶ 23 , quoting State v. Veney, 2008-Ohio-5200 , ¶ 13. {¶ 11} When an appellant seeks to vacate his plea on the basis that the plea was not entered in a knowing, intelligent, and voluntary manner due to the trial court’s failure to comply with Crim.R. 11, the questions to consider are: “(1) has the trial court complied with the relevant pr 2026Specifically, a trial court must “‘must make the determinations and give the warnings required by Crim.R. 11(C)(2)(a) and (b)’” and “‘notify the defendant of his or her constitutional rights enumerated in Crim.R. 11(C)(2)(c).’” State v. Gowdy, 2025-Ohio-5575, ¶ 23 , quoting State v. Veney, 2008-Ohio-5200 , ¶ 13. | 2 | 2026–2026 |
State v. Griggs
green
2 sentences2021When a trial judge fails to explain the constitutional rights set forth in Crim.R. 11(C)(2)(c), the guilty or no-contest plea is invalid ‘under a presumption that it was entered involuntarily and unknowingly.’ [State v.] Griggs, 103 Ohio St.3d 85 , 2004- Ohio-4415, 814 N.E.2d 51 , ¶ 12; see also [State v.] Nero, 56 Ohio St.3d at 107, 564 N.E.2d 474 , citing Boykin [v. Alabama], 395 U.S. [238,] 242-243, 89 S.Ct. 1709 , 23 L.Ed.2d 274 . 2021When a trial judge fails to explain the constitutional rights set forth in Crim.R. 11(C)(2)(c), the guilty or no-contest plea is invalid ‘under a presumption that it was entered involuntarily and unknowingly.’ [State v.] Griggs, 103 Ohio St.3d 85 , 2004- Ohio-4415, 814 N.E.2d 51 , ¶ 12; see also [State v.] Nero, 56 Ohio St.3d at 107, 564 N.E.2d 474 , citing Boykin [v. Alabama], 395 U.S. [238,] 242-243, 89 S.Ct. 1709 , 23 L.Ed.2d 274 . | 2 | 2020–2021 |
State v. Callaghan
green
1 sentence2022“While the court must strictly comply with the requirements listed in Crim.R. 11(C)(2)(c), the court need only substantially comply with the requirements listed in Crim.R. 11(C)(2)(a) and (b).” Id., citing Veney at ¶ 18. {¶13} In order to substantially comply with Crim.R. 11, “a slight deviation from the text of the rule is permissible; so long as the totality of the circumstances indicates that the defendant 9 subjectively understands the implications of his plea and the rights he is waiving[.]” (Internal quotations omitted.) State v. Callaghan, 9th Dist. Summit No. 29431, 2021-Ohio-1047, ¶ 7 | 1 | 2022–2022 |
State v. Irvin
neutral
1 sentence2014Warren No. CA2013-03-027, 2013-Ohio-5209, ¶ 6 , quoting State v. Veney, 120 Ohio St.3d 176 , 2008- Ohio-5200, ¶ 7. | 1 | 2014–2014 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.